Trade Advisory: America First Update

U.S. Strengthens Section 232 Tariffs on Aluminum, Steel, and Copper

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On April 2, 2026, the White House issued a new Presidential Proclamation under Section 232 of the Trade Expansion Act of 1962, strengthening existing tariff measures on imports of aluminum, steel, and copper, as well as certain derivative products. The action follows continued monitoring by the U.S. Department of Commerce and builds upon prior Section 232 actions dating back to 2018.

The Administration determined that imports of aluminum, steel, and copper continue to threaten to impair U.S. national security. As a result, the proclamation reinforces existing tariff regimes and introduces a more uniform framework for how duties are assessed and applied across covered metals and derivative articles.

Core elements of the proclamation include:

Continuation and reinforcement of Section 232 tariffs on aluminum, steel, and copper products based on updated monitoring by the Department of Commerce, which concluded that imports of these metals continue to threaten U.S. national security.

Revised tariff assessment methodology, moving away from metal-content valuation and instead applying duties to the full customs value of covered articles, simplifying prior compliance and valuation disputes.

Standardized tariff rates across covered metals and derivatives, including:

• 50% ad valorem for articles made entirely or almost entirely of aluminum, steel, or copper.
• 25% ad valorem for derivative articles substantially made of aluminum, steel, or copper.
• 15% transitional rates for certain metal-intensive industrial and electrical-grid equipment through 2027 • Exclusions based on material composition, whereby products containing 15% or less aluminum, steel, or copper are removed from Section 232 metals coverage.
• Lower tariff treatment for products manufactured abroad using U.S.-origin aluminum, steel, or copper, reflecting domestic melt-and-pour or smelt-and-cast criteria. Affected products are defined by HTSUS classifications listed in Annexes I-A, I-B, II, III, and IV to the proclamation. Importers should review the annexes carefully to confirm whether specific products fall within scope, qualify for reduced rates, or are expressly excluded from coverage.

What This Means for Importers

Importers of metal products and downstream manufactured goods should expect continued enforcement of elevated Section 232 duties and should review product classifications, material composition, and sourcing documentation to understand potential exposure under the revised framework.

Recommended Next Steps

Importers may wish to:

• Review product bills of materials and metal content thresholds
• Confirm country-of-origin and melt-and-pour / smelt-and-cast documentation
• Monitor CBP implementation guidance and tariff schedule updates
• Evaluate landed-cost impacts and contractual pricing implications

Our Trade Consulting team is monitoring CBP guidance and Federal Register notices related to this proclamation and can assist with product scoping reviews, tariff impact assessments, and documentation planning.

If your organization could be impacted by these potential tariff measures, our Tariff Response Unit is ready to support you. Get immediate guidance on tariff modeling, compliance preparation, and fast-moving regulatory developments.